ML20209B377

Application for Amend to License NPF-5,changing Tech Specs to Provide Exception for Tech Spec 3.0.4 Re Applicability for Loss of Standby Svc Water Sys.Fee Paid

ML20209B377
Person / Time
Site:	Hatch
Issue date:	01/27/1987
From:	James O'Reilly GEORGIA POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20209B383	List: ML20209B377 ML20209B385
References
SL-1913, TAC-64460, TAC-64562, NUDOCS 8702040028
Download: ML20209B377 (6)

Text

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Georgia Fbwer Company 333 Piedmont Avenue Atlanta, Georgia 30308 Telephone 404 526-7851 Marling Address:

Pbst Off.ce Box 4545 Atlanta, Georg:a 30302 e

or V ce Pre dent Nuclear Operations SL 1913 1090C January 27, 1987 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555 NRC DOCKET 50-366 OPERATING LICENSE NPF-5 EDWIN I. HATCH NUCLEAR PLANT UNIT 2 REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

EXCEPTION OF SPECIFICATION 3.0.4 APPLICABILITY FOR LOSS OF STANDBY SERVICE WATER SYSTEM Gentlemen:

In accordance with the provisions of 10 CFR 50.90, as required by 10 CFR 50.59(c)(1), Georgia Power Company hereby proposes a change to the Technical Specifications (TS), Appendix A to Operating License NPF-5 for Plant Hatch Unit 2.

Unlike the other plant emergency diesel generators, standby diesel generator 1B (which is shared between Hatch Units 1 and 2) is normally supplied cooling water from an independent standby service water system.

When the standby service water system is inoperable, the capability exists to provide an alternate safety-grade cooling water supply from the Unit 1 plant service water system. The subject standby service water system was declared inoperable on January 7, 1987 due to inability to meet rated flow requirements and the cooling water supply was switched to the plant service water system. Inoperability of this system resulted in entry into a 60 day Limiting Condition for Operation (LCO) pursuant to TS 3.7.1.2 Action Statement a.4. While under this LCO, on January 26, 1987, Plant Hatch Unit 2 experienced a forced outage unrelated to this condition. TS 3.0.4 prevents entry into different Operational Conditions (e.g. reactor restart) while under the provisions of TS action statements. This Specification thus prevents restart of Plant Hatch Unit 2 from the shutdown of January 26, 1987, while under the provisions of TS 3.7.1.2 Action Statement a.4 Exceptions to TS 3.0.4 are provided throughout TS; however, no such exception is applied to TS 3.7.1.2 Action Statement a.4.

The requested change will provide an exception to TS 3.0.4 for TS 3.7.1.2 Action Statement a.4. This change is requested on an " emergency" basis pursuant to 10 CFR 50.91(a)(5), in that failure to grant the change will prevent restart of the unit. This change is requested as a permanent change to TS. However, it is understood that the requested change may be granted on a temporary, or one-time basis, pending further review.

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L U. S. Nuclear Regulatory Comission January 27, 1987 Page Two Enclosure 1 provides detailed descriptions of the proposed change and the bases for the change request.

Enclosure 2 details the basis for our determination that the proposed change does not involve significant hazards considerations.

Enclosure 3 provides page change instructions for incorporating the proposed change into the Plant Hatch Unit 2 Technical Specifications.

The proposed changed Technical Specifications page follows Enclosure 3.

Payment of the filing fee in the amount of one hundred and fifty dollars is enclosed.

Pursuant to the requirements of 10 CFR 50.91, a copy of this letter and all applicable enclosures will be sent to Mr. J. L. Ledbetter of the Environmental Protection Division of the Georgia Department of Natural Resources.

Mr. James P. O'Reilly states that he is Senior Vice President of Georgia Power Company and is authorized to execute this oath on behalf of Georgia Power Company, and that to the best of his knowledge and belief, the facts set forth in the letter and enclosures are true.

GEORGIA POWER C0FPANY By: \ sk.O'd James P. O'Reill Sworn to and subscribed before me this 27t of January 1987.

, i.wi <wc, uc.Lu, da at Large

' b-f g , , [, My Commission Expires &spt.18,1987 Notary Public REB /lc Enclosures c: Georria Power Company U.S. Nuclear Regulatory Comission Mr. i. T. Beckham Dr. J. N. Grace, Regional Administrator Mr. H. C. Nix, Jr. Mr. P. Holmes-Ray, Senier Resident GO-NORMS Inspector-Hatch Mr. G. R. Rivenbark, Licensing Project Manager Mr. H. R. Denton, Director Office of Nuclear Reactor Regulation State of Georgia Mr. J. L. Ledbetter 1090C

e ENCLOSURE 1 NRC DOCKET 50-366 OPERATING LICENSE NPF-5 EDWIN-I. HATCH NUCLEAR PLANT UNIT 2 <

REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

' EXCEPTION OF SPECIFICATION 3.0.4 APPLICABILITY FOR LOSS OF STANDBY SERVICE WATER SYSTEM 4

BASIS FOR CHANGE REQUEST 1

i The proposed change would add a statement that "the provisions of Specification .(TS) 3.0.4 are not applicable" to TS 3.7.1.2 Action Statement 1 a.4, which covers inoperability of the standby service water system. The standby service water system provides the normal source of cooling water to the 18 diesel generator, which is a shared diesel capable of providing emergency power.to either Hatch unit. Under the provisions of TS 3.7.1.2 e Action Statement a.4, power operation of Plant Hatch Unit 2 is allowed for a period of up to 60 days following a determination of inoperability of this system, provided that cooling for the 18 diesel generator is aligned  ;

l to the Unit 1 plant service water system and operability of this cooling water source is verified per Unit 1 TS.

i The standby service water system was declared . inoperable on January

! 7, 1987, following failure to meet rated flow requirements during surveillance testing. Repairs are expected to require several weeks.

, Power operation under the 60 day LCO continued until January 26, 1987, when a unit forced outage occurred. Due to the lack of a 3.0.4 exemption for TS 3.7.1.2 Action Statement a.4, plant restart cannot be effected without TS relief. Thus, it is hereby requested that a 3.0.4 exemption be provided for TS 3.7.1.2 Action Statement a.4.

The standby service water system provides an additional level of redundancy for diesel generator cooling beyond that required to meet the design basis. With the standby service water system inoperable and the 1B diesel aligned to the Unit 1 plant service water system, no single active i

failure will result in the loss of cooling water to more than one Unit 2 i diesel generator. The NRC's Safety Evaluation (SE) performed in support of

. Amendment 80 to the Plant Hatch Unit 1 (similar to Unit 2) Technical Specifications provides the following information:

j "Only one of the Division 1 Primary Service Water (PSW) pumps and one of the Division 2 PSW pumps are required for cooling diesel j generators 1 A and 1C, respectively, while the standby service water a pump provides adequate cooling water to diesel generator 18. In the

' event that the standby service water pump is inoperable, the HNP-1

- Division 1 - Division 2 intertie supply piping can be aligned to cool the 1B diesel. In this condition, one PSW pump is capable of supplying the cooling requirements for the reactor building cooling system, the control room air conditioners, and the 1 A,1B, and 1C diesel generators. The PSW system can supply all power generation

,l systems at full load and the diesel generators with redundancy if one PSW pump and/or the standby service water pump are inoperable.

ENCLOSURE 1 (Continued)

NRC DOCKET 50-366 OPERATING LICENSE NPF-5 EDWIN I. HATCH NUCLEAR PLANT UNIT 2 REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

EXCEPTION OF SPECIFICATION 3.0.4 APPLICABILITY FOR LOSS OF STANDBY SERVICE WATER SYSTEM BASIS FOR CHANGE REQUEST 1

A single active failure of a component is required in this condition to cause loss of a diesel generator. This condition is within the envelope of accidents analyzed in the Final Safety Analysis Report..."

Thus, the design basis of the plant (both units) is preserved when under the 60 day LC0 for loss of standby service water. The above i evaluation addressed the effects on Unit 1 since the Unit 1 PSW is aligned to the 18 diesel following loss of the standby service water system. Unit 2 PSW is unaffected by the alignment of diesel 1B to the Unit 1 PSW i system. Based on this fact and the availability of the plant service water system on Unit 2, we believe that a 3.0.4 exception is appropriate for TS 3.7.1.2 Action Statement a.4. Since the design basis is preserved, there ^

is no reason to limit power ascension or mode changes. It should be noted that 3.0.4 exceptions are provided for Action Statements a.1 and a.2 of the subject specification, which address inoperability of one plant service f

water pump and one plant service water pump in each loop, respectively.

Either of these conditions is more limiting from a design basis standpoint than loss of the standby service water system.

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1090C El-2 1/27/87 .

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L ENCLOSURE 2 NRC DOCKET 50-366 OPERATING LICENSE NPF-5 EDWIN I. HATCH NUCLEAR PLANT UNIT 2 REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

EXCEPTION OF SPECIFICATION 3.0.4 APPLICABILITY FOR LOSS OF STfNDBY SERVICE WATER SYSTEM 10 CFR 50.92 EVALUATION Pursuant to 10 CFR 50.92, Georgia Power Company has evaluated the enclosed proposed amendment for Plant Hatch Unit 2 Technical Specifications and has determined that its adoption would not involve a significant hazards consideration. The basis for this determination is as follows:

Proposed Change:

Add an exception to Specification 3.0.4, which limits changes of Operational Condition while under the provisions of Action Statements, to Action Statement a.4 of Specification 3.7.1.2, which covers inoperability of the standby service water system at Plant Hatch Unit 2.

Basis for Proposed Change:

The proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated, because the design basis of the plant, as described in the Final Safety Analysis Report, is preserved while under the provisions of the subject Action Statement. In addition, power operation in this condition is allowed for a period of 60 days. Changes of Operational Condition while under the provisions of this Action Statement do not represent a significant increase in the probability or consequences of analyzed accidents.

This change does not create the possibility of a new or different kind of accident from any previously evaluated. The Technical Specifications currently allow up to 60 days power operation without operability of the standby service water system, and provisions are described in the FSAR for aligning the Unit 1 Plant Service Water System to the 18 diesel in the event of standby service water system inoperability, which preserves the design basis of the plant.

This change does not involve a significant reduction in a margin of safety, because adequate margins are preserved when the standby service water system is unavailable and the requested change only provides an allowance for Operational Condition changes while the system is unavailable. No extension of the period of unavailability is requested.

L ENCLOSURE 3 NRC DOCKET 50-366 OPERATING LICENSE NPF-5 EDWIN I. HATCH NUCLEAR PLANT UNIT 2 REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

EXCEPTION OF SPECIFICATION 3.0.4 APPLICABILITY FOR LOSS OF STANDBY SERVICE WATER SYSTEM INSTRUCTIONS FOR INCORPORTATION The proposed changes to Technical Specifications (Appendix A to Operating License NPF-5) would be incorporated as follows:

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